Static vs. Ambulatory interpretation of DTAAs – Retrospective amendments to definition of royalty

ACIT Vs Reliance Jio Infocomm Ltd. (ITAT Mumbai)

Let us appreciate the nature of development, from the treaty perspective, in case one is to hold that the retrospective amendments defining the expression ‘process’ would be equally applicable for definition of ‘royalties’ under the tax treaty. Thus viewed, situation could be like this. There are judicial rulings which decide something in favour of the residence jurisdiction, and the source jurisdiction is not happy with that outcome, and it’s a coincidence, coincide

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